THE "ST. JOSEPH."

(1933) 45 Ll.L.Rep. 180

ADMIRALTY DIVISION.

Before Mr. Justice Bateson.

Bill of lading-Conflict of laws-Belgian Code de Commerce incorporating Hague Rules-Goods purchased by plaintiffs (Guatemalan Government) from French company in Paris-Sellers to deliver at Guatemala City-Transport and insurance undertaken by sellers- Charter by sellers' agents in Antwerp of vessel belonging to defendants (Norwegian shipowners) - Bill of lading (marked "non negotiable") issued in Antwerp-Cargo to be delivered "unto Gouvernement de Guatemala" - Value of cargo not specified-Delivery obtained by plaintiffs' agents by presentation of bill of lading on arrival of vessel at Puerto Barrios-Cargo delivered damaged -Claim by plaintiffs-Claim by defendants to invoke limitation clause in Hague Rules-No reference to Belgian law in bill of lading-Whether implied